Accordance with the Regulation No. 1180/2014 the Ministry of Finance issued the final regulation on transfer pricing on 16 December 2014, which entered into force on 1 January 2015. The final regulation clarifies that the transfer pricing rules and documentation requirements that apply to both domestic and foreign related party transactions. The new regulation also emphasized on:
Information about the transfer pricing policy and method applied, and how the transfer pricing principles are implemented in practice; analysis of how the transfer prices satisfy the arm’s length principle.
Documentation can be submitted to the tax authorities within 45 day upon request.
